Legal · Working draft
Privacy Policy
Version 0.1 · Effective 19 April 2026 · Subject to attorney review and POPIA Information Officer registration
Working draft pending POPIA registration.
This policy describes how we handle your personal information during Fighting Chance's early access period. Registration of an Information Officer with the Information Regulator, and publication of a PAIA manual, are both in progress. If you have any concern about how your data is handled, email support@fightingchance.co.za.
1. Who we are, for privacy purposes
The Responsible Party for personal information you provide to Fighting Chance is the individual founder, pending registration of a private company. The founder acts as the current Information Officer.
Contact: support@fightingchance.co.za, subject line “Privacy.”
2. What information we collect
2.1 Information you provide directly.
- Your name, contact details, and basic identifying information (for account creation)
- Information about your matter — your spouse's name, details of your marriage, information about your children, and your financial situation
- Documents you upload — typically the summons and particulars of claim
- The content you write in each stage — your account of the marriage, your responses to the s7 factors, your counter-proposals
Some of this falls within special personal information under POPIA — notably, information about children and health. We process it only to the extent necessary for the service you have asked us to provide.
2.2 Information collected automatically.
- Your IP address, browser type, and device type (for security and fraud prevention)
- Timestamps of your sign-up acknowledgments, stage completions, and other material actions (for audit purposes)
- Basic usage analytics — which stages you visit, how long you spend, and whether you complete them. We do not use third-party analytics services that profile you.
2.3 Information from third parties.
Currently, none. We do not receive or enrich your data with information from any third-party data broker, credit agency, or similar source.
3. Why we collect it and what we do with it
We process your personal information for the following purposes, each mapping to a lawful basis under POPIA:
| Purpose | Lawful basis |
|---|---|
| Providing the service. Generating AI outputs, saving your progress, producing the matter package. | Performance of a contract |
| Security and fraud prevention. | Legitimate interest |
| Communication. Service-related emails (password resets, account notifications). | Performance of a contract |
| Product improvement. Understanding where users struggle or abandon. | Legitimate interest |
| Legal compliance. POPIA, Consumer Protection Act, Tax Administration Act. | Compliance with a legal obligation |
We do not use your data for marketing, advertising, training publicly-available AI models, selling to third-party data brokers, or profiling you for any commercial purpose.
4. Who we share it with
4.1 Third-party processors.
· Anthropic PBC — provider of the Claude AI models. Your inputs are sent for the limited purpose of generating responses, under terms which prohibit training on customer data.
· [Hosting provider — to be confirmed] — compute and database infrastructure.
· [Email provider — to be confirmed] — transactional email.
When specific providers are confirmed, this list will be updated and affected users notified.
4.2 Your reviewing attorney (Stage 8 only).
When you reach the attorney sign-off stage, we share your matter package with the attorney you have chosen. You control when this happens. The attorney receives the package under their own professional obligations of confidentiality.
4.3 Required disclosure.
We may disclose your data if required by a South African court order, valid subpoena, or regulator. Where not legally prohibited, we will notify you before disclosure. We have never received such a request.
5. Where your data is stored
Our intention is that your data is stored on infrastructure inside South Africa. During early access, the specific deployment region is being verified. Where a third-party processor does not have South African infrastructure, data is transmitted outside SA only briefly to generate a response. Under POPIA s72, transborder data flows for contract performance are permitted.
6. How long we keep it
We retain your data for as long as your account is active, and for 30 days after deletion (for recovery). After 30 days, deletion is irrevocable. Certain data may be retained longer where required by law:
- Financial records related to payment — 5 years under the Tax Administration Act;
- Audit logs of material actions — 3 years for compliance;
- Anonymised and aggregated usage statistics — indefinitely, but cannot identify you.
7. Your rights under POPIA
- Right of access. Request a copy of the personal information we hold. We respond within 30 days.
- Right to correction. Correct inaccurate information directly in the product, or by email.
- Right to deletion. Delete your account and all data at any time.
- Right to object. Object to processing on the basis of legitimate interest.
- Right to data portability. Export all data in standard formats at any time.
- Right to lodge a complaint. Contact the Information Regulator of South Africa at inforegulator.org.za.
8. Security
- Encryption at rest (database-level) and in transit (TLS 1.3);
- Access controls — only the founder has production database access during early access;
- Audit logs of all administrative access;
- Regular backups, encrypted and region-pinned;
- Incident response — breach notification to affected users within 72 hours, and to the Information Regulator per POPIA s22.
9. Children's information
Where your matter involves minor children, you will provide information about them. This is special personal information under POPIA s35. We do not publish, share, or use children's information for any purpose other than producing the matter package. It is deleted with your account.
10. Changes to this policy
Material changes — affecting your rights or how we handle your data — will be notified by email at least 30 days before taking effect. You may export and close your account before the change applies.
11. How to contact us about privacy
Email support@fightingchance.co.za, subject line “Privacy.” We respond within 14 days. For formal POPIA requests (access, correction, deletion, objection), say so explicitly in the subject line.